Business & Human Rights

Global companies face increasingly material and complex human rights and sustainability risk across their operations and value chains. Steptoe's Human Rights & Sustainability team helps leading companies manage these risks and navigate their most difficult challenges with practical, innovative and commercially grounded counsel, informed by decades of experience.

We combine legal rigor with practical solutions to help businesses:

• Integrate human rights and sustainability into enterprise risk management
• Anticipate evolving regulations and litigation risks
• Build trust with stakeholders while protecting reputation and operations

Global, cross-functional team

Our team is led by four Chambers-ranked partners in Business & Human Rights, Environment, Trade, and Investigations. It includes a Senior Advisor to the Voluntary Principles on Security and Human Rights, a Senior Advisor at BSR, and North American advisor to the Global Business Initiative, and a former member of the US Federal Advisory Committee for Responsible Business Conduct. With practitioners in the US, EU, UK, Hong Kong and China, we also draw on Steptoe's bench of recognized leaders in environmental and climate regulation, investigations, disputes, sanctions, privacy, and artificial intelligence to deliver integrated solutions.

Uniquely broad and practical experience

We bring unrivaled experience advising and representing companies across a vast array of industries on all dimensions of human rights governance and regulatory compliance, from enterprise-level assessments to structuring policies and oversight, conducting on-the-ground investigations, engaging with stakeholders and investors, and managing complex crises and disputes. We are also adept in addressing AI-related human rights risks and opportunities, and managing regulatory and litigation risks in grievance mechanism design.

We leverage our rich experience in complex contexts to help companies navigate an array of emerging challenges in disciplines where human rights issues are becoming manifest, such as environmental impacts, climate issues, circularity challenges, trade enforcement, labor and employment matters, health and safety risks, illicit finance and privacy issues. Given the breadth of our experience, we are uniquely situated to address human rights and sustainability dilemmas regardless of how and where they arise.

We advise companies across all industry sectors on complex challenges, including risks embedded in global operations and supply chains. Our experience spans extractives, new energy, automotive, food and beverage, footwear and apparel, electronics, agriculture, manufacturing, technology, communications, aerospace and defence, life sciences, and many other sectors.

Our Relevant Capabilities

Diligence & Investigations

• We conduct global human rights and sustainability risk assessments and targeted due diligence worldwide and across multiple sectors. Our work includes hundreds of investigations and impact assessments in high-risk regions, including conflict-affected areas (CAHRAs). We handle issue-specific reviews such as security and human rights, trafficking, and labor rights, as well as assessments tied to acquisitions, dispositions, and emerging risks.
• We have developed comprehensive value-chain approaches in highly complex circumstances, including traceability schemes for multi-tiered supply chains and downstream due diligence processes involving customers and end-users for off-the-shelf and customizable goods. We have assisted companies in crafting strategies to conduct tailored value-chain monitoring, including through stakeholder engagement, media monitoring, and complaint processes.

Disputes & Crises

• We represent clients in all types of human rights-related disputes, including arbitrations, transnational tort litigation, securities lawsuits, challenges for regional human rights bodies, and quasi-judicial proceedings such as OECD National Contact Point Specific Instances. Our team handles representation in every phase of litigation, including class action claims, and has successfully tried multiple commercial and mass tort cases to verdict in US state and federal courts.  
• We advise clients on sustainability and "green claims" across all stages of their product development and marketing process, and represented a wide range of companies in connection with litigation, pre-litigation demands, and litigation risk reduction strategies.
• We advise clients in managing brand risks related to media and NGO reports. We regularly prepare clients for testimony related to human rights issues before Congressional and Parliamentary Committees, and represent clients in a variety of human rights-related enforcement proceedings and enquiries around the world.

Strategy & Governance

• We advise companies on navigating the interplay of US and EU sustainability regulations, including the EU CS3D, CSRD, Batteries Regulation, Conflict Minerals Regulation, Deforestation Regulation, and Forced Labor Regulation, as well as the US TVPRA, Tariff Act, UFLPA, Federal Acquisition Regulation, and various state trafficking, disclosure, and sustainability regimes.

• We design coherent policies, oversight, and diligence structures to integrate with enterprise risk-management protocols for companies of diverse organizational structures. We have helped create all aspects of value-chain related controls, including appropriate contract provisions, value-chain training, reporting processes, worker engagement and voice programs, and grievance mechanisms.
• We design, implement, and monitor operational and supply chain grievance mechanisms to align with law and meet stakeholder expectations. Our advice is tailored to anticipate evolving legislation and litigation, as well as the dynamics between regulation types and litigation risk—across jurisdictions. We constantly track global legal developments to refine programs and regularly build client-specific legislative trackers leveraging AI.

Reporting & Disclosure

• We advise on inclusion of human rights and sustainability risks in securities filings, reporting specific findings to government authorities, voluntary disclosures in responsibility reports, and compliance with mandatory disclosure requirements in the US (including state-level sustainability disclosures), the UK, and across Europe.
• We have participated in, designed and overseen numerous stakeholder engagement strategies. Each is carefully structured and tailored to the specific context, objectives and sensitivities of each situation, and mindful of legal demands associated with emerging legislation.
• Our lawyers engage with engage with actors in fragile contexts and CAHRAs, leading NGOs and plaintiffs' firms, employees, and local community members.